The organisation is committed to complying with the highest standards of business ethics and has a Corporate Compliance Programme since March 31, 2018, which is periodically reviewed by external consultants of recognised prestige and which sets out, in an organised manner, the measures implemented to create an environment of prevention, detection and early management of risks. Among other things, this programme has a special focus on the fight against criminal and anti-competitive offences, ensuring the highest level of integrity in all business practices. The organisation adheres to the VINCI Codes, which sets out the principles shared by all its employees and business partners and whose fundamental values are defined in the 5 reference documents listed below:

• The Code of Ethics and Conduct, which sets out all the principles of business ethics to be applied in different circumstances and in all the countries in which the firm operates.
• It is used in conjunction with the Anti-Corruption Code of Conduct, which sets out standards to prevent all acts of corruption, in particular by identifying risks in business processes and defining behaviour to be avoided.
• The Human Rights Guide, which summarises potential risks and their impact on the business and defines a common set of guidelines for dealing with human rights issues.  These guidelines are based on the principles of the Universal Declaration of Human Rights (UDHR), the 8 core conventions of the International Labour Organisation (ILO) and the OECD Guidelines for Multinational Enterprises.
• The Declaration on Fundamental and Essential Actions on Safety and Health at Work, which reflects the common will to achieve the goal of ‘Zero Accidents’. The declaration is the result of a constructive and regular social dialogue. As part of a policy of continuous improvement, it reaffirms that progress can only be made with all employees by promoting a culture of safety.
• Environmental guidelines, which provide a framework designed to minimise the risks and impacts of activities on the environment. All companies must follow these guidelines so that policies and procedures can be improved and adapted to protect and preserve the environment wherever they operate. Each business unit is responsible for ensuring that similar efforts are made by business partners throughout the life of a project.

The Corporate Compliance Programme consists of the following documents:

Vinci Regulations

• Manifiesto
• Code of Ethics and Conduct
• Anti corruption Code of Conduct
• Guide on Human Rights
• Environmental Guidelines
• Guide for Users of Information System
• General Cibersecurity Policy
• Essential and fundamental actions concerning Occupational Health and Safety

COBRA SCE Protocols

• Protocol of the Code of Conduct for Business Partners
• Labor Relationship Letter with Subcontractors
• Protocol for Compliance with the Regulations for the Defense of Competition
• Framework Protocol
• Regulatory Compliance Protocol
• Reporting of Alleged Irregularities Protocol
• Corporate Defence Procedure Activation Protocol
• Protocol on Regulatory Compliance Training
• Statute of the Regulatory Compliance Body: Protocol on the profile, experience and organic location of the Regulatory Compliance Body, the Head of Corporate Compliance and the Corporate Compliance Delegate
• Essential Policies Protocol
• Catalogue of Prohibited Behaviours and Expected Behavioural Parameters
• Code of Conduct for Business Partners
• Labor Relationship Letter with Subcontractors
• Protocol for Compliance with the Regulations for the Defense of Competition
• Protocol for Management of Relations with Public Administrations and Civil Servants
• Protocol for Facilitation Payments 
• Sustainability Policy

COBRA SCE Internal Instructions

MASA Regulations

• Code of conduct
• Compliance Management System Manual
• Criminal Risk Management and Bribery
• Professional Courtesies, Donations and Sponsorships
• Relations with Public Officials and Equivalents and Anti-Corruption
• Money Laundering and Terrorist Financing Prevention
• Defense of Competition regulations

Policy and Certificates

• Política de Compliance Penal, Antisoborno y Defensa de la Competencia
• Certificado ISO 37001
• Certificado ISO 37001 (English version)
• Certificado UNE 19601
• Certificado UNE 19601 (English version)
• Certificado UNE 19603
• Certificado UNE 19603 (English version)

Prevention of Money Laundering and Financing of Terrorism

• Third-party declaration
• Third-party declaration (English version)

In addition to reporting to the Corporate Compliance Officer, any person who has knowledge of or suspects any infringement, illegal action, inappropriate behaviour, etc. may use the following means, ensuring at all times that the matter addressed will be confidential and the absence of reprisals for submitting a complaint.

• Digital Platform: https://cobrais.integrityline.com
• Telephone line:
  • Brazil: +55 6 135 507 564
  • Chile: +56 232 149 988
  • Spain: +34 910 477 636
  • Mexico: +52 5 571 002 193
  • Perú: +51 01 640 9418
  • If you choose this method, you will be asked for the service code 22656 during the call.
• Post mail: Canal Ético, Grupo MASA, Calle Vía de los Poblados, 9–11, Edificio C–6, 28033 Madrid (Spain)